SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>wolverine8kltr.txt
<DESCRIPTION>WOLVERINE ITEM 4 8K FILED 8/23/04 COMMENT LTR THOMPSON
<TEXT>

August 24, 2004

Mr. James E. Deason
Wolverine Tube, Inc.
200 Clinton Avenue West, Suite 1000
Huntsville, Alabama 35801

RE:  	Form 8-K Item 4 filed August 23, 2004
	File # 001-12164

Dear Mr. Deason:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your documents in response to
these comments.  If you disagree, we will consider your explanation as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to our
comments on your filing.

Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements and
to enhance the overall disclosure in your filing.  We look forward to
working with you in these respects.  We welcome any questions you may
have about our comments or on any other aspect of our review.  Feel
free to call us at the telephone number listed at the end of this
letter.

1. We read that your former accountant resigned on August 19, 2004.
We also note that your disclosures related to disagreements and
reportable events only address the subsequent interim period through
July 4, 2004.  We refer you to Item 304(a)(1)(iv) and Item
304(a)(1)(v) of Regulation S-K.  Revise your filing to address the
interim period through August 19, 2004, as that is the date of
resignation.  Also revise your filing to clarify the time period
covered by your statement that "there were no reportable events."

2. We read that you engaged your new accountant on August 19, 2004.
We also note that your disclosure related to consultations with the
new accountant prior to engagement only addresses the period through
July 4, 2004.  We refer you to Item 304(a)(2) of Regulation S-K.
Revise your filing to address the interim period through August 19,
2004, as that is the date of engagement.

3. To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter from
your former accountant stating whether the accountant agrees with the
statements made in your amended Form 8-K.  File the amendment under
cover of Form 8-KA and include the ITEM 4 designation.  File the
updated letter from the former accountant as an Exhibit 16.

*****

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.  You may wish to provide us with marked copies of
each amended filing to expedite our review.  Direct any questions
regarding the above to the undersigned at (202) 824-5259.

Sincerely,

Jennifer Thompson
Staff Accountant
Mr. Deason
August 24, 2004
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

       DIVISION OF
CORPORATION FINANCE

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